Letters from Lisbon · No. 41

I run an American company from a Portuguese kitchen table, and I write down everything that breaks.

Seven years ago I filed a Delaware LLC from an apartment in Lisbon with an Italian passport and very little idea what I was doing, and since then I have kept every rejection email, every processing receipt and every date stamp. This journal is that archive, cleaned up, with the federal data behind it pulled fresh so that you can check me.

163Federal complaints mentioning ITIN that I read line by line
7 to 11Weeks the IRS asks you to allow for an ITIN decision
82Of those complaints are about credit files, not bank accounts
0Affiliate links, referral fees or sponsored providers here
The processing times on this page do not stay still

Every waiting period quoted here was measured against the agency that publishes it, and every one of them has moved at least once. When a timing or a fee changes, you get a short note saying what changed and on what date.

One address, no list swaps, and nothing is sent unless a figure on this site actually changed. This is our own reading of public sources and not advice on your own situation.

The setup builder

Answer a short list of questions about your passport, your state, the account you actually want and the paperwork you already hold. It builds the document list, an honest timeline and the two or three things that usually kill an application like yours. It remembers your answers, so you can come back in three weeks and it picks up where you left it.

Saves to this browser

Build my setup

1 · Passport 2 · State 3 · Account 4 · Papers
Questions one and two

Where you are a taxpayer decides your treaty position and how your identity documents have to travel. Where the company sits decides the fees and the annual deadline.

Country notePick a country above.
State exposureAnswer the questions above.
Question three

Every account type below is checked by a different team against a different rulebook. Pick the one you actually need first, because the order matters far more than most people think.

What this account is checked againstPick an account above.
Underwriting notePick what the business does.
Question four

Tick everything you already hold. Anything left unticked lands in the list below with the wait attached to it, in the order I would actually do them.

Answer the questions and this fills in.

Your list

Pick your answers above
Honest timeline, in weeks
Pick your answers and this fills in
What usually kills this one
Please do not treat this as advice. It is my own paperwork and my own reading of public rules. Every case I have seen was different from mine in some way that mattered, so ask an accountant or a lawyer who knows yours.
Nothing saved yet

Two clocks and a folder

The ITIN wait is the longest single block in this whole process and almost nobody plans around it. The left panel turns the published IRS guidance into actual dates on your calendar. The right one is the folder I wish somebody had handed me back in 2019.

Real IRS guidance

The ITIN clock

The IRS asks you to allow seven weeks for notification about a Form W-7 application, and nine to eleven weeks if you file during the filing season between 15 January and 30 April, or if you file from abroad. Almost every reader of this journal falls into the second group, and quite a few fall into both at once.

Why this mattersNothing that needs a taxpayer number moves while this clock runs, so the mistake is starting it after a provider asks for it rather than before. Source: IRS, Individual taxpayer identification number, checked 29 July 2026.

The folder

Fifteen documents, in the order a reviewer opens them. Tick them off as you collect. This stays in your browser, so if you close the tab and come back in three weeks it is still sitting here waiting for you.

0%Nothing collected yet

The complaint file

Every complaint the federal consumer bureau receives is published, searchable by text, with the company and the product attached to it. I pulled every one filed between July 2024 and July 2026 that mentions an ITIN. There are 163. Switch the cut below and watch where they actually land, because it is not where the guides tell you to look.

Pulled 29 Jul 2026
Where 163 ITIN complaints landed

Read this way

Source: CFPB Consumer Complaint Database, full text search for ITIN, complaints received 1 Jul 2024 to 1 Jul 2026, aggregation buckets, pulled 29 Jul 2026. Complaints are allegations rather than findings, and 163 is a small pile, so this describes shape and not statistical significance.

Eight states, side by side

The fifth column is mine and I have not seen it anywhere else. It counts how many federally insured institutions are actually headquartered in each state, pulled from the FDIC register, because the state everybody recommends for its light paperwork turns out to have almost no local banks sitting inside it. Click any heading to sort.

FDIC register, 24 Jul 2026
State Filing fee Every year after Deadline Insured banks based there What it is actually good for

Filing and annual figures are the amounts the states themselves publish for a domestic limited liability company, and they do move, so open the state page in the row before you send anybody money. The bank counts are mine, from the FDIC BankFind register pulled on 24 July 2026, counting active insured institutions by the state of their main office.

The letters

Long ones, because the quick one is already everywhere and it is mostly wrong. Each of these is built on data I pulled myself, with the exact query written down inside it so that you can rerun it and correct me.

9 of 41 shown
54

US bank for foreigners: I read the non-resident score on 10 Bank Index cards, and the only real bank near the top is in Illinois

The 3 largest US banks all score 4.0 for non-resident owners. The top of the list is fintechs, and 1 Illinois bank has a desk for foreign corporations.

24 Sep 20261,856 words
8 min
5 sources
53

How to check MSB registration: what the FinCEN search proves, what it does not, and where a money transmitter license lives

FinCEN does not approve or vet the businesses on its register, a state licence is a separate document, and the enforcement history lives somewhere else again.

23 Sep 20261,849 words
10 min
5 sources
52

I told her the company has nothing to withhold when it pays its own owner, and the definition of a withholding agent does not mention ownership

The definition covers anybody with control or payment of a foreign person’s income, the status applies even when nothing must be withheld, and the liability is personal.

16 Sep 20261,930 words
10 min
3 sources
51

I argued against the 500 dollars for 6 years by comparing it with a number that does not exist

Delaware allows a business to act as its own registered agent only if it is physically located in the state. From Lisbon that option is closed, so the real comparison is a bundle against an agent plus everything else done alone.

15 Sep 20261,863 words
9 min
2 sources
50

I quoted 30 per cent and it was a real rate on a real page, just not the one that applied to them

One bucket taxes profit at graduated rates. The other taxes the gross at a flat 30 per cent with no deductions and no netting. Which one you land in is decided by the business, and a 16 month clock decides whether the deductions survive.

7 Sep 20262,124 words
11 min
4 sources
49

I flew to Miami to open the account, and the rule I was obeying names opening it remotely as an ordinary case

The identification programme asks for 4 items and takes a passport number with the country of issuance. It also requires a procedure for the customer who never appears in person. The rest is one bank's policy.

31 Aug 20262,986 words
15 min
3 sources
48

Sales tax does not ask where you live, and for marketplace sales it does not ask you at all

Washington reaches you at 100 thousand dollars, California at 500 thousand, and neither cares about your passport. The platform collects on marketplace sales, so the exposure that is yours is the direct one.

24 Aug 20262,344 words
11 min
2 sources
47

W-8BEN-E or W-9 for a US LLC: the form follows the owner, not the company

The company is on the list of United States persons and is also disregarded, so the owner signs rather than the entity. The onboarding question asks about the company and never about the owner.

24 Aug 20262,352 words
11 min
2 sources
46

The 1099-K threshold moved 5 times in 5 years and finished where it started

It was 20 thousand dollars, then 600, then 5 thousand, then 2,500, and now 20 thousand and 200 transactions again. The form reports gross, and gross was never your income.

24 Aug 20262,341 words
11 min
5 sources
45

Who is the responsible party for an LLC, and why the bank asks a completely different question

The IRS wants 1 human being who controls the money. The bank wants everyone at 25 percent plus the person who runs the place, and the 2 lists are allowed to disagree.

24 Aug 20262,072 words
10 min
4 sources
44

Form 5472 for a foreign owned LLC: the filing that starts at $25,000 before any tax exists

No US income means no income tax and it does not mean no filing. The wire that opened your bank account is a reportable transaction, and California charges its own 25,000 on top of the federal one.

17 Aug 20262,212 words
11 min
2 sources
43

Do ITIN numbers expire, and the half of you who should do nothing about it

Three consecutive years off a federal return and the number lapses. But an expired number keeps working on 1099s, and the IRS says so in one line I had skimmed for 2 years.

13 Aug 20262,142 words
10 min
2 sources
42

Business credit cards on an LLC with an EIN: I answered the wrong question for two years

I sent people lists of issuers said to take an ITIN. Then I pulled every federal complaint mentioning the number, and three of the four names at the top of the file do not issue cards at all.

4 Aug 20262,303 words
11 min
3 sources
41

ITIN, SSN and EIN: I read two years of federal complaints and the real problem is not the bank

Everybody explains the numbers and then stops. I pulled all 163 complaints that mention an ITIN and found that half of them are not about banking at all, which quietly changes the order you should be doing this in.

29 Jul 20262,197 words
11 min
5 sources
40

Opening a US business account with no Social Security number, path by path

There is no law stopping you. There is an identity stack that cannot see you, which is a completely different problem with a completely different fix, and the fix is boring rather than clever.

14 Jul 20262,109 words
10 min
4 sources
39

I lost my EIN letter: the routes to get the number back, ranked by how long they took me

The IRS will not email it to you and the formation service that filed it often never had it. Here is every route that works from outside the United States, with the real wait attached to each one.

28 Jun 20262,313 words
11 min
3 sources